Justia Mississippi Supreme Court Opinion Summaries

The State appealed the Circuit Court’s order granting partial relief on Michael Drankus’s motion for declaratory and injunctive relief. Drankus, an inmate in the custody of the Mississippi Department of Corrections (MDOC), sought a declaratory judgment that Mississippi Code Section 47-7-3.1 was a mandate to MDOC which required MDOC to develop a “case plan” for all parole-eligible inmates and that MDOC was in violation of that section. Drankus also sought an order that would reverse an adverse decision by MDOC’s Administrative Remedy Program (ARP); an injunction directing MDOC to promulgate policies and procedures that comply with Section 47-7-3.1; and an order directing MDOC to develop a case plan for Drankus. The circuit court ruled only on MDOC’s adverse ARP decision, found that, based on the circuit court’s interpretation of Section 47-7-3.1, Drankus was entitled to receive a case plan pursuant to Section 47-7-3.1. MDOC appealed that decision. Finding that Drankus was not entitled to a case plan, the Supreme Court reversed the circuit court’s order. View "Fisher v. Drankus" on Justia Law

A jury convicted Kelvin Jordan of two counts of capital murder in 1996, for which he received the death penalty. Jordan was denied post-conviction relief (PCR). He filed a successive petition for post-conviction relief in which he argued that his previous attorneys were constitutionally ineffective, that the death sentence is disproportionate, and that the trial judge erred in evidentiary decisions at trial. The Supreme Court held that all of Jordan’s claims except his claim of ineffective post-conviction relief counsel are barred as untimely, as successive, by res judicata, or a combination of all three. His claim of ineffective assistance of post-conviction relief counsel was not permitted to proceed because attorneys were not permitted to raise claims of their own ineffectiveness. View "Jordan v. Mississippi" on Justia Law

A grand jury indicted Jelani Miles for shooting into a vehicle, aggravated assault with a deadly weapon, and murder. The case proceeded to trial but, after the State had called two witnesses, the circuit judge declared a mistrial. When the parties appeared at a hearing to argue the State’s motion to revoke Miles’s bond while awaiting a new trial, the judge transferred the case to a different county over Miles’s objection. The Mississippi Supreme Court granted Miles’s petition for interlocutory appeal to consider the circuit judge’s authority to transfer venue over Miles’s objection. Because the circuit judge lacked that power, the Court reversed and remanded for a trial in Yazoo County. View "Miles v. Mississippi" on Justia Law

In 2012 a jury found James Johnson guilty of aggravated domestic violence against his ex-wife. Johnson’s appeal was assigned to the Court of Appeals, which reversed the judgment and remanded the case, finding that the trial court had erred in admitting evidence of prior bad acts without conducting a proper balancing test. The Supreme Court granted the State’s petition for writ of certiorari. Finding that the Court of Appeals erred in holding that the trial court did not consider the facts contained in offense reports, the Supreme Court reversed the judgment of the Court of Appeals and reinstated and affirmed Johnson’s conviction. View "Johnson v. Mississippi" on Justia Law

Before his capital-murder trial, Laqunn Gary moved to suppress his confession, arguing he had not knowingly, intelligently, and voluntarily waived his Miranda rights. The trial court denied his motion without a hearing. The Supreme Court found that the trial court erred: because Gary had questioned the voluntariness of his confession, he had a due-process right to a suppression hearing. And the State had the burden to prove his confession was in fact voluntary. The Court therefore remanded this case to the trial court to conduct a hearing to determine the admissibility of Gary’s confession. View "Gary v. Mississippi" on Justia Law

In 1992, Arvin Rochell was indicted for two counts of capital murder for killing Hazel and Nell McMahan, and for one count of arson. Arvin Rochell, acting pro se, appealed the Circuit Court’s denial of his petition for post-conviction relief. Rochell styled his petition as a “Motion to Clarify Parole Eligibility” and argued that he was “being unlawfully held in custody due to [the] Mississippi Department of [Corrections’] holding that he is ineligible for parole under [Mississippi Code Section] 47-7-18(1)[.]” Rochell cited the first part of Section 47-7-18(1), which stated that “Each inmate eligible for parole pursuant to Section 47-7-3, shall be released from incarceration to parole supervision on the inmate’s parole eligibility date, without a hearing before the board, if . . .” Relying on this language, Rochell argued that all parole-eligible inmates like himself “are now subject to the new parole release procedures in 47-7-18.” He further argued that the Mississippi Department of Corrections (MDOC) was incorrect when it determined that Section 47-7-18 applied only to inmates sentenced after July 1, 2014, the date that Section 47-7-18 took effect. Rochell argued Section 47-7-18 applied retroactively to all parole-eligible offenders. The Supreme Court concluded that 47-7-18(1) did not apply retroactively to Rochell's case, and affirmed the Circuit Court's denial of post-conviction relief. View "Rochell v. Mississippi" on Justia Law

A jury found defendant Douglas Walters guilty of grand larceny, and he was sentenced to serve ten years in the custody of the Mississippi Department of Corrections. Walters appealed, arguing that the trial court erred in its application of the grand-larceny statute, in quashing a codefendant’s subpoena, and in admitting unauthenticated hearsay into evidence. Finding no error, the Supreme Court affirmed. View "Walters v. Mississippi" on Justia Law

A jury convicted Robert “Bay Bay” Carson of capital murder, being a felon in possession of a firearm, and conspiracy to commit armed robbery, all of which arose from the 2012 shooting death of Juan Ortiz during an armed robbery. Carson received a life sentence without the possibility of parole for his capital-murder conviction, a ten-year sentence for being a felon in possession of a firearm, and a five-year sentence for conspiracy to commit armed robbery. On appeal, Carson argued that his trial counsel was ineffective for failing to request an instruction regarding the unreliability of accomplice testimony and that there was a “reasonable probability” that there would have been a different outcome at trial if counsel had requested the instruction. He also argued that he was entitled to receive his proposed instruction D-6. Find his arguments to be without merit, the Mississippi Supreme Court affirmed his convictions. View "Carson v. Mississippi" on Justia Law

In 2013, Chaddy Brooks looked through her boyfriend’s phone and saw text messages from another woman. The couple got into an argument that later became physical, and ended with Brooks stabbing the boyfriend in the neck with a kitchen knife. Brooks was convicted of second-degree murder and sentenced to serve forty years in the custody of the Mississippi Department of Corrections. She appealed, arguing that there was insufficient evidence to convict her, and that she received ineffective assistance of counsel. Finding no error, the Supreme Court affirmed. View "Brooks v. Mississippi" on Justia Law

Tamra Stuckey was shot and killed on the couch in Charles Kuebler’s apartment in the early morning hours of June 30, 2010. Tamra had been staying at Kuebler’s apartment for three or four days prior and had shown an unreciprocated romantic interest in Kuebler at that time. The trial court allowed the State to introduce evidence of Kuebler’s flight from custody in July 2011, approximately ten months after he was released on bond. The jury returned a verdict finding Kuebler guilty of deliberate-design murder, and the trial court sentenced him to life in prison. In December 2011, Kuebler filed a motion for a judgment notwithstanding the verdict or, in the alternative, a new trial. After a hearing, the trial court denied the motion in October 2012. Kuebler timely appealed. The Court of Appeals found error with the admission of evidence of Kuebler’s flight and the related jury instruction but held that it was harmless error and affirmed Kuebler’s conviction and sentence. After its review, the Supreme Court found that the trial court committed reversible error by denying Kuebler the opportunity to present his theory of defense, in granting a flight instruction, and by prohibiting Kuebler from offering evidence to rebut the State’s argument that his flight indicated consciousness of guilt. Accordingly, the appellate court was reversed and the matter remanded for a new trial. View "Kuebler v. Mississippi" on Justia Law